Computation of Profit

Cases

David Anthony v. Canada (National Revenue), 2016 FC 955

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Tax Topics - General Concepts - Separate Existence taxpayer bound by lease agreements being contracted by his corporation rather than personally 454
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) s. 152(4.2) denials are subject to judicial review 123

Bernick v. Canada, 2004 DTC 6409, 2004 FCA 191

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Tax Topics - General Concepts - Evidence foreign law presumed the same 60
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base cost of bonds equal to their FMV 137
Tax Topics - Income Tax Act - Section 9 - Accounting Principles 173

Bellingham v. The Queen, 96 DTC 6075 (FCA)

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Kaneff Properties Ltd. v. The Queen, 95 DTC 5345 (FCTD)

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Whittles v. Uniholdings Ltd. (No. 3), [1995] BTC 119 (Ch. D.)

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Tax Topics - Income Tax Act - Section 9 - Nature of Income 202

Pollock v. The Queen, 94 DTC 6050 (FCA)

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The Queen v. Cyprus Anvil Mining Corp., 90 DTC 6063 (FCA)

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Magilb Development Corp. Ltd. v. The Queen, 87 DTC 5012, [1987] 1 CTC 66 (FCTD)

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Tax Topics - General Concepts - Evidence 35
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate tentative overtures for subdivision did not effect a change in use 103

Hughes v. The Queen, 84 DTC 6110, [1984] CTC 101 (FCTD)

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Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)

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Silverman v. MNR, 60 DTC 1212, [1960] CTC 262 (Ex Ct)

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Tuxedo Holding Co. Ltd. v. MNR, 59 DTC 1102, [1959] CTC 172 (Ex Ct)

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Royal Trust Co. v. MNR, 57 DTC 1055, [1957] CTC 32 (Ex. Ct.)

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See Also

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) amount subject to potential repayment obligation was not received 240
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) amounts replaced reduced lease income rather than contributing to leased vehicles' cost 217
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing capital tax accrued from day to day 206
Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income 248
Tax Topics - Income Tax Act - Section 9 - Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified 199

Chronis v. The Queen, 2010 DTC 1188 [at 3441], 2010 TCC 218

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Beaudry v. The Queen, 2010 DTC 1266 [at 3853], 2008 TCC 17, aff'd Romar v. The Queen, 2010 DTC 5076 [at 6816], 2009 FCA 48

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Saskferco Products Inc. v. The Queen, 2007 DTC 1183, 2007 TCC 462, aff'd 2008 FCA 297

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange loan repayments on capital account 152

Hollinger Inc. v. The Queen, 98 DTC 1913 (TCC), aff'd 99 DTC 5500 (FCA)

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Bondar v. The Queen, 97 DTC 517 (TCC)

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Federal Commissioner of Taxation v. Energy Resources of Australia Ltd., 94 ATC 4923, [1994] FCA 924 (Full Fed. Ct.)

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Roos v. The Queen, 94 DTC 1094 (TCC)

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) conversion when application for plan of subdivision 189

Marina Québec Inc. v. MNR, 92 DTC 1392 (TCC)

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Street v. MNR, 91 DTC 369 (TCC)

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Jones v. MNR, 90 DTC 1849 (TCC)

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) conversion when retained engineers 152

Mackinnon v MNR, 88 DTC 1651 (TCC)

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Cantor v. MNR, 85 DTC 79 (TCC)

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Gold Coast Selection Trust, Ltd. v. Humphrey (1948), 30 TC 235 (HL)

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Osborne v. Steel Barrel Co., Ltd. (1942), 24 TC 293 (C.A.)

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Administrative Policy

7 February 2018 External T.I. 2016-0673331E5 - Stock Options - CCPCs

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Tax Topics - General Concepts - Fair Market Value - Options FMV of a stock option is higher than its in-the-money value 85

9 May 2016 Internal T.I. 2016-0638461I7 - Vehicle provided to subcontractor

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25 September 2015 External T.I. 2015-0596921E5 - Conversion from inventory to capital

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) no 45(1) on conversion of house inventory to personal use 114

23 December 2013 Internal T.I. 2013-0514701I7 - Bitcoins

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Example

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5 November 2013 CRA Press Release "What you should know about digital currency"

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives capital/income treatment of Bitcoin sales informed by securities trading principles 62

1 November 2013 External T.I. 2013-0501131E5 - Micro-FIT Rental Income

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5 April 2013 External T.I. 2012-0471151E5 F - Binding Agreement

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense counter letter payments non-deductible because Quebec counter letter entered into after apparent letter 217

22 October 2012 External T.I. 2012-0455921E5 - Free Rent in Lieu of Receiving Interest Income

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28 March 2012 External T.I. 2011-0430411E5 - Conversion of capital property to inventory

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22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities

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27 October 2011 Internal T.I. 2010-0382161I7 F - CPN-144 - remises et ristournes

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2004 APFF Roundtable Q. 36, 2004-008704 -

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16 April 2003 Internal T.I. 2002-016080 -

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15 July 2002 Memorandum 2002 - 0151247

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Tax Topics - General Concepts - Fair Market Value - Options 53

2001 External T.I. 2001-009208 -

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 31

11 September 2001 External T.I. 2001-008736 -

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7 March 2001 External T.I. 2001-006896 -

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2 March 2001 Internal T.I. 2001-006651 -

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20 July 2000 Internal T.I. 2000-0035017 - Conversion Capital Property to Inventory

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3 May 2000 External T.I. 1999-001391 -

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Tax Topics - General Concepts - Fair Market Value - Options 49

11 April 2000 Internal T.I. 2000-000132 -

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16 November 1999 T.I. 990214

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14 August 1996 External T.I. 5-961478 -

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24 April 1995 T.I. 942771 (C.T.O. "Securities Lending")

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18 May 1994 External T.I. 5-932991 -

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30 March 1994 T.I. 933722 (C.T.O. "Shares Held as Inventory")

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) 70

4 March 1994 Memorandum 932121 (C.T.O. "Sale of Burial Plots")

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21 February 1994 External T.I. 5-933576 -

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) no s. 45 application to conversion of inventory to personal use 48

1994 A.P.F.F. Round Table, Q. 47, 5M08340

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1 February 1993 T.I. (Tax Window, No. 28, p. 11, ¶2386)

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Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 57

24 December 1992 Memorandum (Tax Window, No. 27, p. 14, ¶2337)

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25 September 1992 T.I. (Tax Window, No. 23, p. 11, ¶2171)

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Tax Topics - Income Tax Act - Section 9 - Accounting Principles 27

8 January 1992 T.I. (Tax Window, No. 27, p. 19, ¶2359)

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92 C.M.T.C - Q.5

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30 November 1991 Round Table (4M0462), Q. 13.1 - Conversion of Capital Property into Inventory Property (C.T.O. September 1994)

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4 September 1991 T.I. (Tax Window, No. 9, p. 20, ¶1445)

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Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 51

90 C.P.T.J. - Q.11

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22 May 1990 T.I. (October 1990 Access Letter, ¶1451)

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IT-490 "Barter Transactions"

IT-102R2 "Conversion of property, other than real property, from or to inventory" 22 July 1985

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IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa" 16 September 1986

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Articles

Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report

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Dent, "Going for the Gold", CA Magazine, January 1990, p. 23

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Harris, "Tax Aspects of Condominium Conversions and Lease Inducement Payments to Recipients", 1986 Conference Report, c.45.

Tetreault, "Canadian Tax Aspects of Asset Securitization", 1992 Conference Report, c.23

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Hudec, Jenkins, "Recent Financial Innnovation in the Canadian Energy Sector", 1991 Canadian Petroleum Tax Journal, Spring 1991, p. 85

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Fryers, "'Net Serve! One to Come!' (The Net Profits Interest in the Oil and Gas Industry - An In-Depth Analysis)", 1988 Canadian Petroleum Tax Journal, Spring 1988, p. 121

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